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BAKER & DANius <br />EST. 1863 <br />FIRST BANK BUILDING • 205 W. JEFFERSON BOULEVARD, SUITE 250 • SOUTH BEND, INDIANA 46601 • (574) 234 -4149 • FAX (574) 239 -1900 • www.bakerdaniels.com <br />EDWARD A. SULLIVAN 111 <br />DIRECT (574) 239 -1930 <br />e -mail: easulliv @bakerd.com <br />July 25, 2002 <br />SOUTH BEND <br />INDIANAPOLIS <br />FORT WAYNE <br />ELKHART <br />WASHINGTON, D.C. <br />QINGDAO, P.R. CHINA <br />VIA HAND DELIVERY <br />Thomas L. Bodnar <br />Assistant City Attorney <br />1400 County — City Building <br />South Bend, IN 46601 <br />RE: Leeper Park <br />Dear Mr. Bodnar: <br />Thank you for your recent letter and proposal regarding parking at Madison <br />School and Leeper Park. We have reviewed your proposal with officials from the South Bend <br />Community School Corporation (the "School Corporation "). The School Corporation believes <br />that the plan you offered fails to provide an arrangement that meets its needs. Thus, we do not <br />believe that it can be the basis for any alteration of the current use of the Leeper Park parking <br />area. <br />As you may recall, at our last meeting (attended by all parties to the litigation and <br />by representatives from the neighborhood), we expressed the School Corporation's need for at <br />least 92 dedicated parking spots. Your proposal does not meet that minimum. In addition, <br />nearly all the proposed parking is located on public streets. This is not an option for the School <br />Corporation since under its collective bargaining agreement with the teacher's union it must <br />provide "adequate off street parking." In addition, we believe you cannot guarantee the passage <br />of a required city ordinance restricting the general public from using those spots. <br />If you would like to discuss these issues further, please feel free to call me at your <br />convenience. <br />EAS /sys <br />Sincerely, <br />BAKER & DANIELS <br />Edward A. Sullivan III <br />SBIMANI 129267v2 <br />